UK export controls may apply to the transfer or disclosure (by any means) of certain goods, software or technology (know-how or other information) from the UK to a destination outside the UK. Such considerations apply to certain research and teaching activities, principally within Engineering and Natural Sciences disciplines. Export controls can apply to items sent or taken out of the UK and to transfers and disclosures by facsimile, e-mail, or other electronic means, as well as telephone or in-person conversations. Under exceptional circumstances, transfers or disclosures made within the UK may be within scope, where it is known or suspected that the ultimate end use is connected to weapons of mass destruction (WMD) related activities outside the UK.
The applicability of export controls and related security concerns should be considered as early as possible when contemplating a proposed research or teaching activity. If an activity falls within the scope of export controls, a licence may be required before any transfer or disclosure can be made. College staff are responsible for assessing their planned activities in the light of published guidance and can contact the Research Office for support and advice in determining export control requirements for research. Export controls and any licences required are administered by the Export Control Joint Unit (ECJU) within the Department for International Trade (DIT) on behalf of HM Government.
It should be noted that failure to properly assess and comply with export control requirements can result in delay, suspension or termination of activities, projects, and other transactions, including loss of associated posts, research awards and funding. Furthermore, exporting controlled items without the required export licence(s) is a criminal offence that may result in fines and even imprisonment. These consequences can damage and disrupt the reputation and work of the individuals involved and the College itself. Please consult the guidance on the College Export Controls website and you can also contact the Research Office for advice and support in navigating potential export control requirements for your activities.
All College staff, particularly academics and researchers, should carefully consider:
- Whether they will need to make exports (transfers or disclosures to recipients outside the UK) as part of their activities; and
- Whether the items (materials or information) that may or will be exported as part of their activities may be sensitive and subject to export controls; and
- Whether there are any material concerns about the recipients of those items, including observance of sanctions and embargoes applicable to any individuals, entities or locations (see HM Government information on current sanctions, embargoes and related restrictions).
Further information, including how to establish when an export licence may be required and how to apply for one can be found on the College’s Export Controls web pages.